Film Partnerships

Below is a selection of our most recent updates on this subject.

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The Revenue Relents

HMRC have backcktracked on their surprise move against film partnerships.
Wednesday, March 14, 2007

New Limits On Use Of Losses

HMRC have announced a surpise move against film parthership and other partnership-based tax planning schemes.
Tuesday, March 06, 2007

Tackling Avoidance - Manipulation Of Film Tax Reliefs

Legislation proposed in December to tackle tax avoidance using film partnerships came into force yesterday, 22 June 2006
Friday, June 23, 2006

Tax Avoidance Using Complex Partnerships And Film Tax Relief

The Government will introduce legislation in the 2006 Finance Bill, effective from today, to counter a complex tax avoidance scheme exploiting the tax relief intended for film production in the UK. Today's measures are aimed at countering tax avoidance by individuals who are partners in businesses where tax relief has been derived from trading losses generated by film tax reliefs. The film tax reliefs operate on a tax deferral basis. Avoidance schemes have been devised which seek to turn this tax deferral into a permanent tax advantage by avoiding the tax charge which would otherwise arise on their share of the partnership's income in later years.
Friday, March 10, 2006

The Small Companies'Corporation Tax Rate - Owners Could See The Rate Of Tax On Their Company's Profits Jump

Owners of small companies who have invested in a film partnership could see the rate of tax on their company's profits jump from 19% to 30% as a result of their investment.
Tuesday, February 14, 2006

Updated HMRC Film Tax Relief Microsite And Revised Guidance

Updated HMRC Film Tax Relief page including information on revised guidance. The new relief, subject to approval by the European Commission, will be available for the production of culturally British films where principal photography starts after 1 April 2006. We also carry links below to the two main film trade bodies 'UK Film Council' and UK Post' where further details of the new rules can be found. Finally we carry a link to the policy document: 'Cultural test for British films: Final Framework' issued by the Department of Culture, Media and Sport in November 2005. A film qualifies as a British film (regardless of whether it is funded from the UK or overseas) if it scores 16 points or more out of 32, broken down into 3 sections. 'Cultural Content' (set wholly / mainly in the UK) contains 4 tests and carries 4 points. 'Cultural Hubs' (must be in the UK) contains 6 tests and carries 15 points. 'Cultural Practitioners' (must be British or EEA nationals / residents) contains 8 tests and carries 13 points.
Wednesday, January 18, 2006

Tackling Avoidance - Manipulation Of Film Tax Reliefs

The Government will bring forward legislation, effective from 20 December 2005, to counter an avoidance scheme which seeks to side-step the current anti-avoidance rules preventing individuals exiting from film partnerships free of tax. The scheme attempts to exploit the film tax relief currently provided by Section 42 of Finance (no. 2) Act 1992 and Section 48 of Finance (no. 2) Act 1997 which is due to be replaced on 1 April 2006. The replacement relief will be targeted exclusively on film production companies and will not be available to investment partnerships and other financial intermediaries.
Wednesday, December 21, 2005

Consultation Document On Proposed New Tax Incentives For British Film Production Issued By Treasury Today

Following the Chancellor's announcement of a review of film tax reliefs at Budget 2005, the Government today published a consultation document setting out proposals for new tax incentives for the production of culturally British films. The consultation 'Reform of Film Tax Incentives: Promoting the sustainable production of culturally British films reflects the Government's view that more can be done to encourage effective and sustained investment while providing better value for money for the British taxpayer and the film-going public according to the Treasury.
Friday, July 29, 2005

Film Partnerships - New Relief Replacing Section 48 Relief

We have updated our library document on film partnerships. The main change is the addition of a section dealing with the new tax relief - we duplicate the beginning. Tax relief on film partnerships is a topical subject. We summarised a recent report from the Times in our bulletin 'From The Papers'. The Treasury is to announce further details in due course. In the meantime we carry a link below.
Tuesday, February 15, 2005

New Tax Relief For Investors In Low Budget British Films From July 2005

The Treasury has announced a new permanent, more generous tax relief for small British films. The legislation for the new relief will be contained in Finance Bill 2005. It will take effect from July 2005 when the old Section 48 relief expires. Details of how the legislation will work are contained in an Inland Revenue guidance note. Please see links below.
Wednesday, October 20, 2004

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